1. Ken Arp Industrial Hygienist Iowa OSHA Consultation and Ed.
Confined Spaces
&
Three New Uses for the Backhoe
For the
Iowa Rural Water Association
Ken Arp Industrial Hygienist Iowa OSHA Consultation and Ed.
Direct
General

2. OSHA and CONFINED SPACES Objectives
Define “Confined Space”
Define “Permit Required Confined Space”
Explain the Hazards of Confined Spaces
What is a “Safe” Confined Space Entry?

3. Which would you rather have?

4. OSHA STANDARDS ON CONFINED SPACES
29 CFR
29 CFR (b)(4) [welding]
29 CFR (o) [telecommunications]
29 CFR (b)(6)(i)
29 CFR [excavations]
29 CFR 1915 Subpart B [shipyards]

5. Current Confined Spaces Standard for Construction
(b)(6)(i)
“All employees required to enter into confined or enclosed spaces shall be instructed as to the nature of the hazards involved, the necessary precautions to be taken, and in the use of protective and emergency equipment required. The employer shall comply with any specific regulations that apply to work in dangerous or potentially dangerous areas.”

6. Current Confined Spaces Standard for Construction
(b)(6)(ii)
Means any space having a limited means of egress, which is subject to the accumulation of toxic or flammable contaminates or has an oxygen deficient atmosphere. … storage tanks, process vessels, bins, boilers, ventilation or exhaust ducts, sewers, underground utility vaults, tunnels, pipelines, and open top spaces more than 4 feet in depth such as pits, tubs vaults and vessels.

7. Confined Space A space that is:
large enough and so configured that an employee can bodily enter and perform assigned work; and
has limited or restricted means for entry or exit (e.g., tanks, vessels, silos, storage bins, hoppers, vaults, pits); and
is not designed for continuous employee occupancy
Starts ELO 4.2

8. Standard Safety Requirements for Confined Spaces (ANSI Z117.1-2003)
“Restricted entry and exit is a physical configuration, which requires the use of the hands or contortion of the body to enter into or exit from a confined space”.
Limited - when an employee would be forced to enter or exit in a posture that might slow self-rescue or make rescue more difficult (FR 11/4/94, p ).
10/27/95 – Mr. William Taylor (ELB & Associates) Q#3 under what circumstances might dikes be considered confined spaces and further when would they be permit spaces? Answer: As a contaminant structure, the design of a dike will determine whether it falls within the def. of PRCS std. A dike formed of mounded or sloped earth to a height of 4-6 ft would not normally represent a restricted means for entry or exit. Conversely, a dike formed of a vertical block or concrete wall of the same height would constitute a restricted means for entry or exit. Potential hazard of engulfment or the potential of a hazardous atm from a heavier-than-air gas or vapor would be considered.

9. Questions to Ask
Does the person have to use their hands to enter or exit the space?
Is the person in an awkward posture when entering or exiting the space?
Is a person’s entry into or exit from the space slowed down or impeded by physical obstructions (such as pipes, ductwork, walls, holes in the floor, flanges, etc.)?
Would an employee be forced to enter or exit in a posture that might slow self-rescue or make rescue more difficult?
person have
Summarize limited/restricted means of entry/exit by these questions - have class write these questions in their manuals on this page.
Does the person have to use their hands to enter or exit the space?
Is the person in an awkward posture when entering or exiting the space?
Is a person’s entry into or exit from the space slowed down or impeded by physical obstructions (such as pipes, ductwork, walls, holes in the floor, flanges, etc.)?
Would an employee be forced to enter or exit in a posture that might slow self-rescue or make rescue more difficult?

10. CONFINED SPACE RESTRICTED ENTRY/EXIT
Not designed for continuous occupancy
LARGE
enough to bodily enter
CONFINED
SPACE
Confined space triangle
OK - it’s time to look at a couple of slides & using the definition of confined space, let’s determine if the following photos are confined spaces or not.
RESTRICTED
ENTRY/EXIT

11. What about Dry Wells or Lift Stations? Confined Space? Depends

13. Permit-required Confined Space
A confined space with hazards = a PRCS
Hazardous Atmosphere
<19.5% O2 (Oxygen Deficient)
> 23.5% O2 (Oxygen Enrichment)
>10% LEL for gas or vapor
>100% LEL for combustible dust
> IDLH
> PEL + acute, serious & impairs ability to escape
Take them to the definitions of Permit Space and Hazardous Atmosphere in their standards.
<19.5% (Oxygen DEFICIENT atmosphere)
>23.5% (Oxygen ENRICHED atmosphere)
>10% LEL
> 100% LEL for combustible DUST
> IDLH
> PEL + acute, serious & impairs ability to escape

14. Permit Space (cont’d) ENGULFMENT ENTRAPMENT
OTHER SERIOUS RECOGNIZED HAZARDS
Energy Sources
Electrical
Mechanical
Pneumatic
Hydraulic, etc.
Steam
Corrosives, etc.
ENGULFMENT
ENTRAPMENT
OTHER SERIOUS RECOGNIZED HAZARDS
- Energy Sources
Electrical
Mechanical
Pneumatic
Hydraulics, etc.
- Steam
- Corrosives, etc.

15. Take class to CPL (p.15)
Question #1 “Ladders and temporary, movable, spiral, or articulated stairs will usually be considered a limited or restricted means of egress. Fixed industrial stairs that meet OSHA standards will be considered….when conditions or physical characteristics of the space…would interfere with the entrant’s ability to exit or be rescued in a hazardous situation.”
Fixed industrial stairs
Stair strength (min. of 1,000 lbs); stair width (min of 22”); angle of stairway rise (angles to the horizontal between 30 and 50 degrees - Table D-1 gives Rise/Tread dimensions that meet this requirement); tread (reasonably slip-resistant); railings and handrails (at least one side - refer to ); vertical clearance (at least 7 ft)
Show next slide….

16. He hasn’t moved in 15 minutes, should we do something?
Contingency Plan
GOT ONE?

17. Is this a confined space? ______
Semi-truck – not a confined space because it’s not limited or restricted (instructor will show slide of semi backed up to a loading dock).
Could also talk about - designed for continuous occupancy (since people will be loading and unloading the truck).
Is this a confined space? ______
Why or why not? ___________________________________

18. Is this a confined space? ______
This is a water tank truck – entry is on top through a hatch. This is a confined space.
Is this a confined space? ______
Permit Required? ___________________________________

19. Is this a confined space? ______
Permit Required? ___________________________________

20. Is this a confined space? ______
Underground utility vault. This is not a confined space (standard industrial ladder – not considered limited or restricted)
Is this a confined space? ______
Why or why not? ___________________________________

21. Is this a confined space? ______
This is a pressurized vessel – entry is on top. This is a confined space
Is this a confined space? ______
Permit required? _________________________________

22. Is this house (providing this is the only exit) now a confined space?
I think our means of egress has just been restricted!
Is this house (providing this is the only exit) now a confined space?

23. Is this a confined space? ______
This is a mixer. Is a confined space and would be a PRCS because of the mechanical hazard (someone turning on the mixer while a worker was in it). There may be other hazards like noise, cut, struck by, etc.
Is this a confined space? ______
Is this a permit-required confined space? ______
If yes, what hazards make this confined space a permit space? ___________________________________________

24. Is this a confined space? ______
Rusted pipes in pit
Chlorine pit for the swimming pool - enter to repair rusted lines; annual or semi to check the conditions of the pit area.
Chlorine gas is main hazard.
Yes – confined space
Yes - PRCS
Is this a confined space? ______
Is this a permit-required confined space? ______
If yes, what hazards make this confined space a permit space? ___________________________________________

25. Is this a confined space? ______
Yes, both are confined spaces
Probably PRCS, too – main hazard would be atmospheric depending on chemical being hauled (foreground: railroad tank car) or stored in the storage tanks (in background)
Is this a confined space? ______
Is this a permit-required confined space? ______
If yes, what hazards make this confined space a permit space? ___________________________________________

26. Sanitary Sewer Manholes
Respect these places
Tell them what to look at and why this is important.
Can a person get into this?
Is it considered limited/restricted? (ladder)
Is it designed for continuous human occupancy?
Is this a PRCS? yes
What are the hazards that make sanitary sewers PRCSs? Hazardous atmosphere including possible oxygen deficiency, methane, hydrogen sulfide, a multitude of toxics….. Also, possible engulfment depending on laterals….
Is this a confined space? ______
Is this a permit-required confined space? ______
If yes, what hazards make this confined space a permit space? ___________________________________________

27. Examples of Confined Spaces
Pits (e.g., elevator, escalator, pump, or valve)
Manholes (e.g., sewer, electrical, or communication)
Tanks (e.g., fuel, water, or other liquid/solid/ gas)
Boilers
Transformer vaults

28. Examples of Non-Permit Confined Spaces
From FR 1/14/93, p. 4475:
Vented vaults
Motor control cabinets
Dropped ceilings
Other examples MAY include:
Crawl space under buildings
Air handling units (HVAC systems)*
October 27, 1995 letter to Mr. James Sharpe (Consolidated Engineers Services) - includes cooling towers, trap doors, attics, crawl spaces, soffit spaces, fan chambers, return air shafts, etc.
Tab #2 (Classification), letter #10

29. Again, these can be very dangerous
This is a stormwater man hole.
This is a confined space
Could be classified as a PRCS – hazards could include engulfment and oxygen deficiency.
Is this a confined space? ______
Is this a permit-required confined space? ______
If yes, what hazards make this confined space a permit space? ___________________________________________

30. Is this a confined space? ______
Elevator Pit
Elevator pit
Yes – confined space
Could be permit-required confined space – mechanical hazards
Yes – PRCS (mechanical and struck by hazards)
Is this a confined space? ______
Is this a permit-required confined space? ______
If yes, what hazards make this confined space a permit space? ___________________________________________

31. Is this a confined space? ______
This is an example of a non-permit space.
Is this a confined space? ______
Is this a permit-required confined space? ______
If yes, what hazards make this confined space a permit space? ___________________________________________

32. Is this a confined space? ______
This is a storage tank. You can see the hatch on top – this is a confined space.
Could be permit space due to potential hazardous atmosphere (i.e., oxygen deficiency, toxics, flammables) & engulfment hazards.
Is this a confined space? ______
Is this a permit-required confined space? ______
If yes, what hazards make this confined space a permit space? ___________________________________________

33. Permit Required? Hazards?
Confined Space?
Permit Required? Hazards?
Actual or Potential?

34. Confined Space Incidents
>60% of the fatalities resulted from hazardous atmospheres.
% of fatalities are would-be rescuers.
Usually entrants nor rescuers fully recognized the potential hazards associated with confined spaces.
Most common hazardous atmospheres were
<O2, methane, CO, H2S (in order)

35. 4 Gas Meter
Safe Conditions?

36. Or would this look better?

37. Limitations of Air Testing Devices
You need to know how to use it WELL
Sensitivity varies
Interference
Poisoning/Shelf Life of Sensors
Temp/Humidity Operating Range
Some Not Intrinsically Safe
Must Be Zeroed/Recalibrated
Battery Life
Hazards must be known

38. Clearing the Air
Why do atmospheres account for a majority of the fatalities?

39. BAD AIR Will incapacitate YOU
Quickly
20,000
Gas Meters
Oxygen Deficient
Hydrogen Sulfide
Carbon monoxide
Carbon dioxide
Nitrogen

40. Oxygen Deficiency 21% - Normal O2 level
19.5% - Minimum permissible O2 level
15-19% - Impaired coordination
12-14% - Pulse up, impaired judgement
10-12% - Respiration increases further, lips blue
8-10% - Fainting, ashen face
6-8% - 100% fatal in 8 minutes, 50% fatal in 6 minutes, 4-5 minutes recovery with treatment
4-6% - Coma in 40 seconds, convulsions, death

41. The Incidents
2 employees die from hydrogen sulfide at oil well – gas meters with employees
Sioux City lagoon deer rescue
Carbon dioxide 1 fatality
Nitrogen – 2 fatalities - Tanker
Anhydrous Ammonia fatality

43. Ventilation “controls”

44. What is a “Safe” Atmosphere
Less than 10% of lower flammable limit
19.5% to 23.5% Oxygen
Atmosphere below the permissible exposure limit
In addition, OSHA can cite for failure to provide adequate training for employees entering confined spaces. However, OSHA policy dictates that where a standard does not prescribe specific criteria, such as is the case with , the Agency must establish that the cited employer failed to provide the instructions that a reasonably prudent employer would have given in the same circumstances.
With regard to references and cross references between part 1910 and 1926 standards, please be advised that before June 30, 1993, OSHA would cite certain 1910 standards where they applied at construction sites. On June 30, OSHA incorporated the General Industry standards which have been identified as applicable to construction work into part While other part 1910 standards may be identified in the future as applicable to construction, this compendium represents all of the part 1910 standards that have presently been identified as applicable. OSHA does not cross reference general industry and construction standards.

45. Is 20% Oxygen “Safe?”
How much oxygen is missing if your meter reads 20%?
What’s 1% in parts per million?
10,000
Are there any gasses at 10,000 ppm that could harm you?
Hundreds
Carbon Monoxide is deadly at 500ppm
ALWAYS TEST THE ATMOSPHERE

46. Which would you rather have?

47. And Finally, Last, and least important
Three new uses for that backhoe

48. backhoe bucket / trench box - NOT
Trench – not under the standard

49. Knocking Down Really Tall Stuff - NOT

50. Shade on a hot day - NOT

51. Thank You, It’s time to run